Executive Summary

Easy access to cheap, abundant oil has created a high standard of living for many cultures and societies. At the same time, the extraction, refining, distribution, and use of this oil – as energy and in products – is increasingly undermining many of our planet’s life forms and the fragile balance of conditions that support climate stability and human prosperity. These effects are occurring on local, regional, and global scales.

This report characterizes the risks posed to wild salmon by a Trans Mountain pipeline spill into the Lower Fraser River or a tanker spill into the Salish Sea. The Lower Fraser River flows from Hope past Mission, through Metro Vancouver, and into the estuary where it meets the Pacific Ocean.

The Fraser River remains one of the world’s most productive salmon rivers. Today, it still supports dozens of unique populations of Pacific salmon (Chinook, chum, coho, pink, and sockeye), as well as interior and coastal populations of steelhead and trout. These species support First Nations culture and economies and have done so for thousands of years. More recently they have been harvested in commercial and recreational fisheries. Overall, the Fraser River and its tributaries are home to 42 different species of fish, including seven species of Pacific salmon (genus Oncorhynchus) and two species of trout (genus Salmo). However, many of these species and populations now face a crisis due to decades of habitat loss, fishing, and more recently, climate change.

The Fraser River’s estuary is equally important, supporting fish, bird, and mammal species that are linked across thousands of kilometers of the Northeast Pacific Ocean. All Fraser River populations of Chinook, sockeye, coho, pink, and chum must transit the estuary twice in their lifetimes: once as they migrate to the ocean as juveniles and again as adults when they return to their natal streams to spawn. Many salmon species also spend extended time rearing in the estuary as they prepare for their ocean migrations.

As of 2018, roughly one-third of the Fraser River watershed’s unique salmon and steelhead populations were considered at risk of extinction. Tweet This!

A crude proposal: The Trans Mountain expansion

In 2013, Kinder Morgan applied to the National Energy Board (NEB) to expand their existing oil pipeline, which runs for 1,150 kilometres from Strathcona County, Alberta to Burnaby, British Columbia (BC). The proposed expansion requires construction of approximately 994 kilometres of new pipeline across more than 500 watercourses, roughly half of which support habitat for recreational, economic, and culturally important fish species.

The increased pipeline capacity (from 300,000 barrels per day to 890,000 barrels per day) would necessitate a dramatic increase in the number of tankers transiting the waters of the Salish Sea. The number of Aframax class vessels (tankers that can carry up to 850,000 barrels of oil) departing Burnaby would increase from the current five tankers per month to 34 per month, increasing inbound and outbound transits from an existing 120 to 816 tanker trips per year.

Essential rearing habitat for juvenile salmon in the Canadian waters of the Salish Sea. Essential nearshore and estuary rearing habitat is depicted in green (<20 metres) and diamonds (estuaries). Larger immature and migrating young salmon will also occupy the deeper photic and mid-depth zones.

Trans Mountain’s existing pipeline extends from Strathcona County, AB to Burnaby, BC. The proposed expansion would twin this pipeline, almost tripling the oil capacity from 300,000 barrels per day to 890,000 barrels per day. The new pipeline would cross roughly 250 streams and rivers that support spawning salmon in the Fraser River watershed.

Even with Trans Mountain’s simplification of the highly complex Fraser River, their spill modelling results still estimate a high probability (up to 90%) of oil stranding along shorelines in the spring, winter, and fall. Tweet This!

Diluted bitumen

The expanded pipeline would carry primarily diluted bitumen (dilbit), a petroleum product that consists of solid or semi-solid bitumen diluted so it can flow through pipelines. For dilbit originating in Alberta, condensate is the most commonly used diluent. Condensate is a petroleum by-product composed primarily of very light, highly flammable, and acutely toxic components.

Spilled dilbit can behave differently in the environment depending on the type of dilbit and the conditions at the time of the spill. Certain conditions, including sediment in the water, make it more likely that dilbit will sink. Higher salinity can also contribute by making it easier for oil to combine with sediment. These conditions occur in the Lower Fraser River, which carries roughly 20 million tons of sediment a year, has a salt water wedge occurring upstream to New Westminster and tidal waters as far as Mission. Both this sediment and salt water increase the likelihood that dilbit will submerge below the surface and sink.

Dilbit that has submerged or sunk is extremely difficult to recover. Once oil has submerged below the water’s surface, there is almost no ability to detect, contain, or recover that oil. In cases where oil sinks, recovery is unlikely unless the spill occurs in sheltered, accessible locations, and even then, the environmental cost of oil recovery can exceed the benefits.

Spilled dilbit can also strand on shorelines, and the complexity and variability of features in the Lower Fraser River make this highly likely. Natural features found in the river include sandflats, mudflats, marshes, backwaters, braided channels, gravel beds, and debris. Man-made features include log booms, kilometers of riprap and armoured shorelines, and other industrial developments. These diverse features provide many opportunities for spilled oil to wash up along shorelines, where it is extremely challenging, if not impossible, to recover. These complexities were not considered by Trans Mountain in their spill modelling, which assumed a simple, straight channel.

In 2010, a ruptured Enbridge pipeline released 3.2 million litres of dilbit into the Kalamazoo River. As of 2013, up to 636,000 litres of dilbit remained on the river bed because the environmental costs of further clean up were deemed to outweigh the benefits.

Juvenile salmon migrate downstream to the Fraser River estuary starting in March and continue through the spring and summer. After spending one to four years at sea, mature salmon return to their natal streams via the Lower Fraser River throughout the spring, summer, fall, and even winter for some populations. Their fertilized eggs will incubate for several months before the tiny fry emerge. Thus, there are embryos, out-migrating juveniles or returning adult salmon in the Lower Fraser River every month of the year. There is no time when salmon are not present.

Oil and salmon: A toxic mix

With nine species of salmon and trout spawning in the tributaries of the Lower Fraser River and using the main channels and sloughs to rear, a spill of dilbit into the river or its tributaries would be catastrophic, rendering many of these areas unsuitable for the growth and survival of salmon embryos and fry.

Juvenile and adult salmon can be exposed to spilled oil via oil droplets in the water column, toxic components of oil that have dissolved in water, and through consumption of contaminated prey. However, embryonic fish (developing inside the egg), are most at risk because critical development is occurring at a rapid rate, and the embryos themselves are immobile and unable to escape exposure.

Unfortunately, some of the same characteristics that create attractive salmon spawning habitat (e.g. flowing, oxygen rich water) can also increase the likelihood that salmon embryos will be exposed to the toxic components of spilled oil. Toxins dissolved in the water flowing through the spawning beds can permeate the egg, affecting the development and survival of the tiny embryo.

After eggs are fertilized, oil exposure has been shown to significantly increase mortality rates of embryos. For salmon embryos that do survive, exposure to oil can cause impaired heart function, physical deformities, reduced growth, and compromise their ability to produce offspring. This could mean effects across entire populations of salmon that are already facing multiple challenges to their survival.

Fertilized salmon eggs can be present in spawning gravels from late summer of one year to spring of the following year, providing a long window of potential exposure to toxic oil components. In addition, a spill can affect not only those embryos present at the time of the spill, but the embryos of future generations. Oil trapped in the river bed does not wash out quickly, and the slow release of sunken and stranded oil can result in concentrations of toxic compounds in the water that are high enough to cause embryotoxicity for months to years.

This is a critical consideration in the case of the proposed pipeline expansion. Spilled dilbit is likely to strand on beaches and sink to bottom sediments, where it can create a long-term source of contamination not just to salmon embryos, but to other aquatic life, including the invertebrate species that are a key food source for salmon.

In 2010, a ruptured Enbridge pipeline released 3.2 million litres of dilbit into the Kalamazoo River. As of 2013, up to 636,000 litres of dilbit remained on the river bed because the environmental costs of further clean up were deemed to outweigh the benefits.

There is no safe time for an oil spill in the Lower Fraser River

We all have images in our minds of mammals and birds exposed to oil spills, but salmon are no less vulnerable to the impacts of spilled oil. Oil spilled into the Fraser River or one of its tributaries would spread quickly over the water’s surface and be carried downstream. Oil spilled from a tanker traveling through the marine waters of the Salish Sea could quickly arrive on the shoreline of the Fraser River estuary. Both present unacceptable risks given the fragility of salmon populations and the critical importance of the Lower Fraser River’s remaining habitat, which is used year-round by wild salmon.

As of 2018, 20 of the Fraser River watershed’s 56+ unique salmon and steelhead populations (called Conservation Units for federally managed salmon) were considered at risk of extinction. This includes ten sockeye conservation units, Interior Fraser coho, and two steelhead populations all listed by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC). Seven Chinook Conservation Units are identified as Red under Canada’s Wild Salmon Policy and are under review for listing by COSEWIC.

Year-round salmon habitat

Juvenile salmon migrate downstream to the Fraser River estuary or to the Strait of Georgia starting in March and continuing through the spring and summer. After spending one to four years at sea, mature salmon return to their natal streams via the Lower Fraser River throughout the spring, summer, fall, and even winter for some populations. Their fertilized eggs will incubate for several months before the tiny fry emerge. Thus, there are embryos, out-migrating juveniles or returning adult salmon in the Lower Fraser River every month of the year. There is no time when salmon are not present.

Harrison River Chinook, one of the largest Chinook runs in North America, migrate downstream to the Lower Fraser River and estuary as fry immediately after their emergence from spawning gravel. They rear in tidal creeks and marshes from March to June, or longer, before ocean entry. Other Chinook juveniles use the Lower Fraser River and estuary habitats during their downstream migration from April to July. Adult Chinook return to the Fraser River starting in April and continue through to October.

Interior Fraser coho salmon migrate as juveniles down through the Lower Fraser River from March to June on their way to sea, and adults migrate from October to December when they return to spawn. Endangered sockeye populations migrate through the Lower Fraser River as fry from late March to June on their way to sea. Adult sockeye return to spawn from May to December.

Fraser River chum salmon spawn at 78 sites in the Lower Fraser, including the main channel. The embryos and fry are present in the spawning grounds from September to as late as June. Fraser River chum migrate as fry to the tidal marshes of the estuary between March and June. The adults return to spawn from September through January.

In addition to concerns for the continued existence of these salmon, the habitat they rely on to spawn, rear, feed, and grow has dramatically declined in both quantity and quality. The salmon that return to the Fraser River watershed cannot sustain further losses to their numbers or their habitat, but a pipeline spill (and even its construction in some places) would do just that, affecting salmon and their habitat for years to decades.

No safe time for an oil spill

Fraser River salmon are vulnerable to an oil spill based on their species life history and their life stage. Whether as embryos, juveniles or adults, salmon are present in the Lower Fraser River every month of the year.

Interior Fraser coho salmon

Listed as threatened by COSEWIC (2016).

Adults migrate into Lower Fraser from October to December.

Juveniles migrate out of the Lower Fraser from April through June.

Lower and other Fraser River coho

Adults return to the Lower Fraser from August through February and spawn in dozens of Lower Fraser tributaries.

Juveniles use the Lower Fraser tributaries and estuary year-round.

Embryos are present in spawning beds from October through May.

Fraser River sockeye

Adult sockeye return to the Lower Fraser from June through December.

Juveniles migrate out of the Lower Fraser between March and July.

There are 10 Conservation Units (populations) of Fraser sockeye listed as threatened or endangered by COSEWIC, three of which reside in the Lower Fraser (Cultus

Lake, Upper Harrison Lake and Widgeon River).

River-type sockeye juveniles (such as the Harrison population) rear in the Lower Fraser River and estuary until July, making them more vulnerable to oil spills than lake-type populations.

Fraser River Chinook

Adult Chinook return to the Lower Fraser from February to November.

Harrison River Chinook (one of the largest runs in North America) migrate downstream to the Lower Fraser River and estuary as fry. They rear in tidal creeks from April to

June, but can stay up to 4 months before going to sea.

Seven Fraser River Chinook Conservation Units (populations) have been assessed as ‘Red’ under Canada’s Wild Salmon Policy (2016). This represents 64% of assessed CUs, and 33% of all Fraser River Chinook CUs.

Fraser River chum

Spawn at 78 sites in the Lower Fraser River, including the main stem.

Adults return to spawn from September through January.

Embryos, alevins, and fry are present in intertidal gravel as early as September and as late as June of the following year.

Juveniles migrate to the tidal marshes of the estuary between March and June and can stay up to 4 months.

Chum spawn in approximately 227 streams and rivers outside the Fraser River that drain to the Salish Sea.

Fraser River pink

Fraser River pink salmon follow a two year cycle with high and low abundance in odd and even years, so juvenile and adult vulnerability is highly dependent on the year.

In odd years, more than five million chum can return to the Fraser River.

Approximately 70% spawn in Lower Fraser River and tributaries between Mission and Hope.

Embryos and alevin are present in gravel from September until as late as June.

Marine spills threaten Salish Sea estuaries

The Strait of Georgia (part of the Fraser River estuary) is considered the most important rearing area for juvenile salmon on Canada’s Pacific coast. In addition to the Fraser River, 190 large and small estuaries critical for salmon rearing, staging, and migration lie within the Salish Sea. Five of these (the Nicomekl/Serpentine River, Cowichan River, Chemainus River/Bonsall Creek, Nanaimo River, and Courtenay River) rank in the top 10 estuaries in British Columbia for their ecological value. These estuaries are vulnerable to oil spills from either a pipeline or an oil tanker.

Prior to their migration to sea, juvenile salmon must spend significant time in the Fraser and other estuaries transitioning to the marine environment. During this time, fish experience physiological stress and are highly sensitive to additional stress. Further, it may be impossible for them to avoid spilled oil while they are undergoing this process in the estuary.

Ocean-type Chinook, chum, and some coho salmon have the greatest reliance on estuaries and would be particularly vulnerable to a pipeline or tanker spill affecting the Fraser River estuary and other estuaries throughout the Salish Sea.

Use of local estuaries and near-shore habitats by different salmon species and life-history types

Misleading and flawed information

We examined information put forth by Trans Mountain in their assessment of the effects to salmon from an oil spill in the Fraser River and found serious deficiencies with several aspects of their assessment.

These deficiencies render their conclusions unsubstantiated. These include:

In modelling the potential for spilled oil to strand in the Fraser River, Trans Mountain assumed a straight channel without complexities of log booms, rip rap, or infrasture. This underestimates the potential volume of stranded oil.

Trans Mountain did not address the possibility of submerged and/or sunken oil in either their modelling or spill response plans.

Detection limits in the study used to inform their modeling of the fate and behaviour of spilled dilbit were three orders of magnitude higher than concentrations at which effects on fish have been observed.

Trans Mountain’s assessments of turbidity/ TSS in the Fraser River, an important factor in whether dilbit sinks, were qualitative, and failed to use the most precise quantitative assessments.

Trans Mountain indicated in their submission that the formation of Oil-Sediment Aggregations (OSA), which increase the likelihood of sinking, would not be a dominant fate of spilled oil. This is despite the findings of Environment Canada, who found that various types of sediment material resulted in the formation and subsequent sinking of OSAs.

It is unclear whether TransMountan would use chemical dispersants like Corexit in freshwater or enclosed environments.

Corexit and the use of dispersants

Dispersants move oil from the water’s surface into the water column. While potentially reducing the volume of oil washing up on shorelines, dispersants can increase the toxicity of the oil by increasing the concentration of oil in the water. The combination of oil and dispersant together has also been shown to be more toxic than either product alone. Lastly, dispersants can suppress the ability of microbes to degrade oil.

So why use dispersants?

The answer may be a question of optics. Undispersed oil can eventually reach shorelines, coating birds and mammals and providing visual images of oil spill consequences. Dispersing oil can reduce the likelihood of oiled shorelines and oiled wildlife that create public relations problems for those responsible for the spill.

Conclusion

This report identifies the potential for further declines in Fraser River salmon populations associated with an oil spill that contaminates spawning, rearing, and migrating salmon habitat. It details the factors that Trans Mountain failed to consider when presenting their environmental assessment, and the uncertainty about how the products shipped in the pipeline will behave when spilled in wild salmon habitat of the Fraser River, Fraser estuary, or Georgia Strait.

We have shown that Fraser River salmon are vulnerable to an oil spill based on their species life history. Whether as embryos, juveniles or adults, salmon spawn, rear, and migrate throughout the Lower Fraser River every month of the year. As such, there is no safe time for an oil spill. Further, the geography of the lower Fraser River makes effective oil recovery extremely difficult, if not impossible, resulting in the likelihood of long-term releases of the toxic components of oil. Twenty populations of Fraser River Chinook, sockeye, coho, and steelhead are already at low (or critically low) abundance. These populations are even more vulnerable to extinction as a consequence of random events like oil spills. All of these facts undermine government and industry assurances that risk and consequences to salmon from the Trans Mountain expansion are minimal.

As part of the Fraser River estuary, the Strait of Georgia is considered the most important rearing area for juvenile salmon on Canada’s Pacific coast. In addition to the Fraser River, 190 estuaries critical for salmon rearing, staging, and migration lie within the Salish Sea. These estuaries are vulnerable to oil spills, either from a pipeline or an oil tanker.

To give wild Pacific salmon the chance they need to rebuild as strong, abundant, and resilient populations, we must find new ways to foster economic prosperity. These solutions are available but they require bold, innovative thinking from all levels of government.

One-third of the wild salmon populations in the Fraser River are considered at risk of extinction. This is a clear indication that economic, social, and environmental considerations are not in balance. If the government of Canada does build the Trans Mountain pipeline, it must do so knowing this decision clearly jeopardizes Canada’s greatest salmon river and a fish considered the lifeblood of British Columbia.

We hold the future in our hands. The choice to not expand the Trans Mountain pipeline is ours. To give wild Pacific salmon the chance they need to return to strong, abundant, and resilient populations, we must turn to new and innovative ways to solve our energy and economic problems.

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